View source for A98016, Application for Amends to Licenses DPR-39 & DPR-40,restoring Plant Custom TS Replaced by Improved TS by Previous Amend & Reinstating License Conditions Deleted by That Previous Amend

{{Adams
| number = ML20217H927
| issue date = 03/30/1998
| title = Application for Amends to Licenses DPR-39 & DPR-40,restoring Plant Custom TS Replaced by Improved TS by Previous Amend & Reinstating License Conditions Deleted by That Previous Amend
| author name = Brons J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = ZRA98016, NUDOCS 9804060122
| package number = ML20217H931
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 16
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Commonw calth litison Company
  /jon Generating St.uion Inl Shiloh Houlo ard t.,on. nlam 2 r Tel 8 n~' ' 46-208 i ZRA98016 March 30,1998 U. S. Nuclear Regulatory Commission ATFN: Document Control Desk Washington, DC 20555

==Subject:==
Application for Amendment to Facility Operating Licenses to Restore Custom Technical Speci0 cations, Reinstate Previous License Conditions, Change                  ;
Management Titles and Responsibilities, Allow use of Certified Fuel Handlers,           j Change Shift StaffinF nd Crew Composition, and Eliminate Verbiage implying that         {
the Units are Operati,an. I                                                             !
I Zion Station Units I and 2                                                              l Facility Operating Licenses DPR-39 and DPR-40                                           i NRC Docket Nos. 50-295 and 50-304                                                        l

==References:==
See Attachment F M
Pursuant to 10 CFR 50.90 Comed proposes to amend Facility Operating Licenses DPR 39 and DPR-40 and Appendix A to those Licenses. The proposed amendment is being requested to facilitate plant activities following the permanent shutdown and defueling of Units 1 and 2. The proposed amendment would restore the Zion Station Custom Technical Specifications (CTS) that had been replaced with improved Technical Speci6 cations (ITS) by a previous amendment and would reinstate License Conditions that were deleted by that previous amendment.
The proposed amendment would also change management titles and responsibilities to reDect the permanently shutdown organization, modify the CTS to allow use of Certi0ed Fuel Handlers to satisfy Shift staf5ng requirements, allow a reduction in the number of personnel required on shifl, and eliminate verbiage in the CTS that implies that the units are operational Comed requests approval of this amendment prior to June 1,1998.
This proposed amendment request is subdivided as follows:
Attachment A provides a description and safety analysis of the changes proposed by this amendment.
Attachment B provides a copy of the affected pages of the CTS, annotated to show the l         changes proposed by this amendment request, and provides a clean copy of the affected pages with the proposed changes incorporated.
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March 30,1998 Page 2 U. S. Nuclear Regulatory Commission Attachment C provides Comed's evaluation, performed in accordance with 10 CFR 50.92(c), which confirms that no significant hazards consideration is involved.
Attachment D provides an Environmental Assessment in accordance with 10 CFR 51.21.
Attachme .. L provides a listing of the commitments made by Comed in this amendment request.
In Reference 6, Comed requested an amendment to the ITS to authorize new techniques for sleeving steam generator tubes. CemEd hereby withdraws the amendment request submitted via Reference 6.
This proposed amendment has been reviewed and approved by Comed Onsite and Offsite Review organizations in accordance with Comed procedures.
  ' Comed is notifying the State ofIllinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.
Please direct any questions you may have concerning this submittal to this office.
Respectfully, GL ohn C. Brons Site Vice President Zion Nuclear Station Attachments cc:       NRC Regional Administrator- Rlli Office of Nuclear Facility Safety - IDNS IDNS Resident inspector Senior Resident inspector - Zion Station Zion Station Project Manager - NRR 1
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STATE OF ILLINOIS Docket Nos.                                                            50-295 50-304 IN THE MATTER OF COMMONWEALTH EDISON (COMED) COMPANY l
ZION STATION - UNITS 1 AND 2 AFFIDAVIT l
1 affirm that the content of this transmittal is true and correct to the best of my knowledge, information and belief.
                                                                                                                   \
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ohn C. Brons                                              l ite Vice President Zion Nuclear Station
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Subscribed and sworn to before me, a Notary Public in and                   !     THERESA1.SIAT                  i
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ATTACHMENT A License Amendment Request Number 98-05, Revised Section 6.0, Administrative Controls to renect Defueled Status ZION NUCLEAR GENERATING STATION DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES TO FACILITY OPERATING LICENSES DPR-39 AND DPR-48 APPENDIX A TECHNICAL SPECIFICATIONS
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES A.       

==SUMMARY==
OF PROPOSED CIIANGES Pursuant to 10 CFR 50.90 Comed proposes to amend Facility Operating Licenses DPR-39 and DPR-40, and Appendix A to those Licenses.
The proposed amendment is being requested to facilitate plant activities following the permanent shutdown and defueling of Units 1 and 2, which has been -
documented in References 1 and 2. The proposed amendment requests restoration of the station's Custom Technical Specifications (CTS) that had been replaced with Improved Technical Specifications (ITS) by previously issued Amendments (178/165). Although Amendments 178/165 were issued in December 1997 (Reference 3), they have not been implemented and Comed has continued to conduct plant activities in accordance with the CTS. The proposed amendment would maintain CTS as the specifications governing activities at Zion Station. As part of the restoration of the CTS, the five License Conditions (2.C.(4),2.C.(7)(b),
2.C.(8),2.C.(9),and 2.C.(10)) which were deleted by Amendments 178/165 would be reinstated.
The proposed amendment would also change certain provisions of Section 6 of          l the CTS ," Administrative Controls." These changes would alter certain
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management titles and responsibilities to reflect the permanently shutdown plant     '
organization, allow use of Certified Fuel Handlers in lieu of 10 CFR 55 licensed personnel, reduce the required number of personnel, change the required composition of the on-shift crew, and alter verbiage which implies that the units are still operational.                                                               1 The proposed changes are described in detail in Section E of this Attachment.
Attachment B provides a copy of the affected pages of the CTS, annotated to show the changes proposed by this amendment request, and provides a clean copy       !
of the affected pages with the proposed changes incorporated.                        j H.        DESCRIPTION OF THE CURRENT REQUIREMENTS                                    i Amendments 178/165 was issued to replace the CTS in their entirety with the
! ITS. Section 2 of the amendment deleted the following license conditions:
2.C.(4)        The licensee shall not operate the reactor in Mode 1 or 2 (as dermed in Technical Specification Table 1.1) with less than four (4) reactor ;
coolant loops in operation until safety analyses for less than four loop operation have been submitted and approval for less than four l                                            1 l

I ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES loop operation in Mode 1 or 2 has been granted by the Commission by amendment to this license.
2.C.(7)(b)   No loads heavier than the weight of a single spent fuel assembly plus the tool for moving that assembly shall be carried over fuel stored in the spent fuel pool. The spent fuel handling tool, the burnable poison tool, the rod cluster control changing fixture and the thimble plug shall not be carried at heights greater than two feet over fuel stored in the spent fuel pool.
2.C.(8)    The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shallinclude:
(a) Identification of a sampling schedule for critical parameters and control points for these parameters; (b) Identification of the procedures used to quantify parameters that are critical to control points; (c) Identification of process sampling points; (d) Procedure for the recording and management of data; (e) Procedures defining corrective actions for off control point chemistry conditions; and (f) A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events required to initiate corrective action.
2.C.(9)    The licensee shall implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident to as low as practicable levels. This program shall include the following:
: 1. Provisions establishing preventive maintenance and periodic visual inspection requirements, and
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: 2. Integrated leak test requirements for each system at a frequency not to exceed refueling cycle intervals.
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES 2.C.(10) The licensee shall implement a program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:
: 1. Training of personnel,
: 2. Procedures for monitoring, and
: 3. Provisions for maintenance of sampling and analysis equipment.
Section 3 of Amendments 178/165 stated that the amendment was effective as of the date ofissuance (December 19,1997) and that the amendment was to be implemented prior to Unit 2 entering Mode 4. Ilowever, neither unit will be entering Mode 4 and Amendments 178/165 will not be implemented.
Accordingly, as stated in the letter from John C. Brons, Comed, to the               1 U. S. NRC, dated February 12,1998 (Reference 4), Comed is continuing to use the CTS to govern plant activities.
Section 6 of the existing CTS describes responsibilities of the Chief Nuclear Ofricer, the Site Vice President, and the Station Manager.
Section 6 of the existing CTS defines responsibilities and/or qualifications and/or minimum shift staffing requirements for Shift Operations Supervisors, Operating Engineers, Shift Engineers, Shift Control Room Engineers, Shift Foremen, Nuclear Station Operators, Equipment Operators, Equipment Attendants, and radiation protection personnel.
Section 6 of the existing CTS contains verbiage in several places that implies that the units are still operational.
C.       BASES FOR TIIE CURRENT REQUIREMENTS At the time that Amendments 178/165 were issued, both units were in extended i outages with Unit I defueled and Unit 2 in Mode 5. The requirement that the amendment be implemented prior to Unit 2 entering Mode 4 was based on the belief that that both Zion units would ultimately return to operation, and that Unit 2 would be the first to be restarted.
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES The five license conditions were deleted based on the relocation of requirements contained in four of the conditions to the ITS and the relocation of the requirements of one of the conditions to the UFSAR.
The responsibilities of the Chief Nuclear Officer, the Site Vice President, the Station Manager as defined in Section 6 of the CTS are based on the position functions and titles that are applicable to operational nuclear power generating stations under Comed's Nuclear Generation Group.
I The responsibilities and/or qualifications and/or minimum shift staffmg requirements for Shift Operations Supervisors, Operating Engineers, Shift Engineers, Shift Control Room Engineers, Shift Foremen, Fuel llandling
                                                                                       ~  l Foremen, Nuclear Station Operators, Equipment Operators, Equipment                     j Attendants, and Radiation Protection personnel as defined in Section 6 of the CTS       l are based on the shift staffing that is appropriate for an operational nuclear power plant.                                                                                  ;
I D.       NEED FOR REVISION OF TIIE REQUIREMENT                                         i Comed is submitting this amendment request because several immediate license            l changes are needed to facilitate the transition of Zion Station from an operational     l to a permanently shutdown and defueled status.                                          l Although Comed has continued to use the CTS to govern plant activities,                 l preparations for ITS implementation were in progress when the decision was made to permanently cease operations at Zion Station. Comed ultimately plans to         j propose an entirely new set of Permanently Defueled Technical Specifications           i that are applicable to the plant in the permanently shutdown and defueled               l condition and that have no provisions for operational modes or conditions that          j will not occur. Consequently there is no benefit to expending the resources that would be needed to complete the ITS implementation process. Comed is therefore proposing that the CTS be restored as they existed through Amendments 177/164, and that the five deleted License Conditions be reinstated. Comed acknowledges that some of the five License Conditions may not serve a useful function with the plant in the permanently shutdown and defueled condition.
Ilowever, these will be reviewed and dispositioned when Comed proposes the l Permanently Defueled Technical Specifications, j
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!                                  ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES Additionally, Comed has identified changes to Section 6.0 of the CTS,
  " Administrative Controls," that are needed in the near future. These changes fall   {
into four categories; changes in management titles and responsibilities, changes to  1 allow use of Certified Fuel Handlers in lieu of 10 CFR Part 55 licensed operators, .
changes in shift staffing numbers and crew composition, and changes in certain verbiage to eliminate the implication that the units are operational.
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! The management titles and responsibilities specified in Section 6.0 of the CTS L need to be changed to reflect the transfer of responsibility for Zion Station to Comed's Decommissioning Projects organization. Although the Chief Nuclear Officer will continue to have ultimate responsibility for safety at Zion Station, direct corporate responsibility will be assigned to a Corporate Vice President.
There will no longer be a Site Vice President position. The Station Manager l position will be replaced by the Decommissioning Plant Manager who will fulfill l responsibilities assigned to the Site Vice President in the CTS. The Operations      j l Manager position will be replaced by the Decommissioning Operations Manager.
Appropriate changes to Section 6.0 of the CTS are needed to reflect these
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organizational changes.                                                              J L Since Zion Station will no longer be operational, there is no longer a need for l
l operators trained in the tasks associated with operations in Modes 1 through 7 and j licensed in accordance with 10 CFR Part 55. Therefore, Comed has submitted (Reference 5) for NRC approval, a Certified Fuel llandler Training and Retraining
( Program which describes training and qualification requirements that are l appropriate for operators at a permanently defueled facility. Changes are needed to Section 6.0 of the CTS to recognize these new qualification requirements and      {
allow use of Certified Fuel Handlers in lieu oflicensed operators.
There are far fewer tasks involved with the safe storage and handling of nuclear l fuel than with an operational nuclear power plant. Therefore, fewer personnel will be needed on the shift crew and the functions that define the shift crew l composition will change. Consequently changes to the shift staffing requirements l in Section 6.0 of the CTS are needed to reflect the changes in manning needed for a permanently shutdown and defueled plant.
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l Finally, there are several locations in Section 6.0 of the CTS in which the verbiage could imply that the plant is still operational. These typically occur      j when the terms " operation" or " operating" is applied to the terms " unit" or       j
  " plant." Re-wording of this type of verbiage is needed to preclude confusion or misunderstanding.
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L                                      ATTACHMENT A L
DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES E.        DESCRIPTION OF THE PROPOSED CHANGES Listed below are the CTS sections affected by this amendment request and a description of the proposed changes.- Attachment B to this letter provides a copy
;    of the affected pages of the CTS, annotated to show the proposed changes, and a e
_ clean copy of the affected pages with the proposed changes incorporated.
f    Section 6.1, Organization In Paragraph 6.1.1 the words " unit operation" have been deleted and replaced j         with " station" to remove the implication that either unit will operate. The l         term " nuclear power plant" has been eliminated to remove the implication that l         the plant produces power. The paragraph now emphasizes that that the primary concern is the safe storage and handling of nuclear fuel.
In Paragraph 6.1.1.b, the term " Station Manager" has been replaced with the       ,
term " Decommissioning Plant Manager" for consistency with the titles              !
established by Comed's Decommissioning Projects organization. The remainder of the statement has been re-worded to remove the implication that either unit will operate, and to clearly establish that the primary concern is the safe storage and handling of nuclear fuel.                                         )
In Paragraph 6.1.1.c, the term "The Chief Nuclear Officer (CNO)" has          j l         been replaced with the term "A Corporate Vice President." Although the             l Chief Nuclear Officer will continue to have ultimate responsibility for safety     i at Zion Station, direct corporate responsibility will be assigned to a Corporate   j Vice President. The responsibilities of the Corporate Vice President have          )
i         been redefined to be those that specifically relate to the safe handling and       l l         storage of nuclear fuel.                                                           !
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In Paragraph 6.13, the term " Operations Manager" has been replaced with the       l term " Decommissioning Operations Manager" for consistency with the titles         i established by Comed's Decommissioning Projects organization. The terms            ;
          " Shift Operations Supervisor,"" Operating Engineer,"" Shift Engineer,"" Shift Foreman," and " Fuel Handling Foreman" have been deleted since these positions will no longer be necessary. The requirement for a Senior Reactor        ,
Operators license has been replaced with a requirement to be a Certified Fuel Handler since the Certified Fuel Handler Training and Retraining Program will provide the knowledge, skills, and abilities needed to ensure the safe storage and handling of nuclear fuel. The requirement to be a Certified Fuel Handler has been imposed on individuals fulfilling a supervisory role to 6

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l                                  ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES ensure the safe storage and handling of nuclear fuel when these individuals are directing the activities of other personnel.
Paragraph 6.1.3 has also been changed such that the responsibilities pertaining to the Fire Protection Program that belonged to the Site Vice President will belong to the Decommissioning Plant Manager since the Site Vice President position will be eliminated. The term " Operating Engineer" has been changed to " Decommissioning Operations Manager" for consistency with the titles l    established by Comed's Decommissioning Projects organization.
Paragraph 6.1.3.a has been added to require that all fuel handling operations be directly supervised by a Certified Fuel Handler since the Certified Fuel llandler Training and Retraining Program will provide the necessary knowledge, skills, and abilities to supervise such operations. Paragraph 6.1.3.b has been added to designate that individuals holding a current Senior Reactor Operators license are qualified as Certified Fuel Handlers.
In Paragraph 6.1.4, the training and education requirements of the Decommissioning Operations Manager have been defined as equivalent to qualifications of the Operations Manager discussed in ANSI N18.1 " Selection    I and Training of Nuclear Power Plant Personnel," dated March 8,1971, with the exception that this individual may be qualified as a Certified Fuel Handler upon appointment to that position in lieu of holding a Senior Reactor Operator  i license. In addition, the training and education requirements for the Shift      I Control Room Engineer have been deleted. The CTS did not require this position to be manned unless there was a unit in Mode 1-4 or 7.
A new Paragraph 6.1.7 has been added to require that a training and retraining program for Cenified Fuel Handlers be maintained under the direction of the      j
,    Decommissioning Plant Manager or his delegate. This ensures that an appropriately controlled program is used to qualify Certified Fuel IIandlers.
Section 6.2, Procedures and Programs                                                !
In Paragraph 6.2.1.i the requirement to limit the routine heavy use of l    overtime has been changed such that it applies to the plant staff who perform l
functions important to the safe storage and handling of nuclear fuel, rather than the " Shift Engineer, Shift Control Room Engineer, Shift Foreman, and Nuclear Station Operator" since those positions will no longer exist.
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES In the introductory paragraph of Section 6.2.3," Station Manager" has been changed to " Decommissioning Plant Manager" as the position responsible for identifying other procedures affecting nuclear safety. This change has been made for consistency with the titles established by Comed's Decommissioning Projects organization.
In paragraph 6.2.3.B, " Station Manager" has been changed to
     " Decommissioning Plant Manager" as the position responsible for approving individuals who perform technical reviews. This change has been made for consistency with the titles established by Comed's Decommissioning Projects organization.
In paragraph 6.2.4.B. the requirement that temporary procedure changes be approved by a Senior Reactor Operator has been replaced by a requirement that temporary procedure changes be approved by a Certified Fuel 11andler.
There will be no need for personnel to hold 10 CFR 55 licenses with the plant    ,
permanently shutdown and defueled. Personnel who are Certified Fuel              l liandlers will have the knowledge, skills, and abilities needed to adequately review such changes.
Section 6.3, Action to be Taken in the Event of a Reportable Event in Plant Operation The phrase"...in Plant Operation" has been deleted from the title of Section 6.3 to remove the implication that the section is not applicable with the plant in a non-operational status. Section 6.3 has also been changed such that Reportable Events will be reported to the Decommissioning Plant Manager rather than the Site Vice President. The Site Vice President position will be eliminated and the Decommissioning Plant Manager will be the highest l
position on site.
L Section 6.4, Action to be Taken in the Event a Safety Limit is Exceeded Section 6.4 required that shutdowns caused by exceeding a Safety Limit be reported to the Site Vice President. Since the Site Vice President position is    !
not included in Comed's Decommissioning Projects organization, and since it is no longer possible to exceed a Safety Limit, the entire section has been
    . deleted.
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l ATTACHMENT A l
DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES Section 6.7, Offsite Dose Calculation Manual (ODCM)
In paragraph 6.7.b " Station Manager" has been changed to " Decommissioning Plant Manager" as the position responsible for approving changes to the ODCM. This change has been made for consistency with the titles established by Comed's Decommissioning Projects organization.
l Section 6.9, Process Control Program l
In Section 6.9.b " Station Manager" has been changed to " Decommissioning l
Plant Manager" as the position responsible for approving changes to the Process Control Program. This change has been made for consistency with the titles established by Comed's Decommissioning Projects organization.
Figure 6.1-1, Minimum Shift Crew Composition Figure 6.1-1 has been completely revised to require a minimum shift crew composed of a Shift Supervisor and two non-certified operators. This shift composition is adequate to perform the tasks associated with safe storage of
;     nuclear fuel.
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A new item (a) has been added to provide replacement instructions for those provided by the " MINIMUM *" staffing levels in the previous Figure 6.1-1.
The wording is adopted from the generic Improved Standard Technical
;     Specifications (NUREG 1431) and provides more explicit instructions than l     were provided in the previous Figure 6.1-1. An additional restriction has been added to ensure minimum staffing is maintained at shift tumover.
I     A new item (b) has been added to require at least one person qualified to stand watch in the control room (non-certified operator or Certified Fuel Handler) be present in the control room whenever nuclear fuel is stored in the fuel storage pool.
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES l
F.      SAFETY ANALYSIS OF THE PROPOSED CHANGES l    The individual proposed changes may be grouped and analyzed as follows:
l    Restoration of CTS and Reinstatement of Five Deleted License Conditions This change is administrative in that the ITS were never implemented. As evidenced by the stipulation in Amendments 178/165 that the ITS w ;re to be implemented prior to Unit 2 entering Mode 4, the CTS were considered adequate to govern plant activities with one unit in Mode 5 and one unit defueled. With .
both units defueled, the plant in many respects presents even less risk. Therefore, continued compliance with the CTS in lieu of the ITS does not decrease overall plant safety.
There has been no interruption in the requirement to comply with the CTS.
: l. Compliance with the CTS was continuously required during the preparations for        ,
ITS implementation. This provides assurance that there have been no inadvertent l
!    lapses in required Surveillance testing due to the previously planned transition     j from CTS to ITS. In anticipation of defueling operations, Comed conducted a review to verify that departmental procedures were correct for changing from         ;
Mode 5 to Mode 6. To provide additional assurance, Comed is also conducting a        1 l    review to verify that procedures and tracking systems continue to accurately l    reDect the CTS requirements that are applicable at all times including a review to   j l    ensure that CTS Section 6 required programs have not been affected.                  l Reinstatement of the Gye License Conditions that were deleted by ITS                 )
i-   amendment presents no safety concern since these License Conditions were             i l    previously considered to be adequate in conjunction with the CTS. The License        i l    Conditions will be reinstated exactly as they were prior to the ITS amendment        !
even though some of them provide no safety beneSt with both units defueled.          j Chances In Manacement Titles and Responsibilities Due to Transfer to p_ecommissionine Proiects Oreanization l
These changes are administrative and will not result in any decrease in the quality of management applied to Zion Station nor in the overall degree protection of public health and safety. The Station and corporate management team will report to the responsible corporate Vice-President, who reports to the CNO.
The elimination of the Site Vice President position is consistent with the signincant reduction in site activities, site staf0ng, and risk to public health and to

j ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES safety that occurs when an oper$tional nuclear power plant transitions to a
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permanently shutdown and defueled plant. The Corporate Vice President                J Responsible for Zion Station will have the authority to commit personnel and         !
resources necessary to fulfill the obligations for safe storage and handling of      j nuclear fuel, and to execute decommissioning activities.
The change of position designations from " Station Manager" to
  " Decommissioning Plant Manager," and from " Operations Manager" to                  ,
  " Decommissioning Operations Manager" will in no way reduce the respective           l responsibilities of these positions for overall protection of public health and safety. The specific responsibilities for these positions, as described in the CTS    i and in Sections 3.4.1.3.1.2.1 and 2 of the Comed Quality Assurance Manual, will be focused more narrowly (i.e., on those programs and activities necessary to ensure the safe storage and handling of nuclear fuel). The qualifications of the station decommissioning management staff will continue to meet the requirements of CTS Section 6.1.4.
In addition, the qualifications of the Decommissioning Operations Manager are defined as those of the Operations Manager provided in ANSI 18.1," Selection         j and Training of Nuclear Power Plant Personnel," dated March 8,1971, with the         ;
exception that this individual may be qualified as a Certified Fuel Handler upon appointment to that position in lieu of holding a Senior Reactor Operator license. l Benlacement of Reauirements fbr 10 CFR 55 Licenses with Reauirements for             ]
Certified Fuel Handlers This change is appropriate based on the significant reduction in the required        j knowledge, skills, and abilities of operations personnel that occur when a plant is  i permanently shut down and defueled. In this condition none of the reactor plant manipulations, transients, or accidents that are associated with an operational unit l are of concern. Accordingly much of the knowledge, skills, and abilities required    I to obtain a 10 CFR 55 license are no longer applicable. The NRC has recognized       !
this and has defined the position of Certified Fuel Handler in order to provide an   !
alternative to operators licensed per 10 CFR 55 for permanently shutdown and defueled plants. As stated in 10 CFR 50.2. Certified Fuel Handlers must be           l qualified in accordance with a training program approved by the NRC.
Comed has submitted its Zion Station Certified Fuel Handler Training and Retraining program for NRC approval. This program has been developed using a Systems Approach to Training as defined in 10 CFR 55.4. The program will ensure that the qualifications of personnel are commensurate with the tasks to bc
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ATTACHMENT A                                        )
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;                     DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES performed (i.e., the monitoring, handling, storage, and cooling of nuclear fuel in a  1 manner consistent with ensuring the health and safety of the public).                J Chances in Shift Staffine Numbers and Crew Composition These changes are appropriate based on the number, complexity, and hazard level of the activities required for storage and handling of nuclear fuel as compared to -
the activities associated with an operational dual unit nuclear power plant. The corresponding reduction in manipulations of plant apparatus and simplification of.
command, control, and coordination functions mean that the number of operations personnel can be significantly reduced with no loss of protection to the health and safety of the public.                                                                I The elimination of the Shift Control Room Engineer does not result in any l reduction in safety since the existing CTS only require that the position be manned in Modes 1-4 and 7. The significant reduction in activities involving radiological hazards means that the CTS requirement for continuous onshift presence of a Radiation Protection Person can be eliminated with no loss of protection to the health and safety of the public. Radiation Protection coverage will be determined in accordance with the station's Radiation Protection and          l Emergency Preparedness programs. Station procedures will require that a Radiation Protection Person be on site during handling ofirradiated fuel.
Chances in Verbiace to Eliminate Imnlication that Units are Operational These changes will not reduce overall safety and may improve it by precluding         l confusion or misunderstanding regarding responsibilities with the plant permanently shutdown and defueled.
G.      IMPACT ON PREVIOUS SUBMITTALS In Reference 6, Comed requested an amendment to the ITS to authorize new
! techniques for sleeving steam generator tubes. Comed hereby withdraws the l amendment request submitted via Reference 6.
l II. SCI 1EDULE REQUIREMENTS Comed requests approval of this amendment request by June,1.1998, to support the planned transition to permanently defueled staffing levels.
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